03/01/2012 The European Federation of Investors (EuroInvestors) welcomes the opportunity to comment on the draft proposal for EIOPA’s Report on Good Practices for Disclosure and Selling of Variable Annuities (the “Report”). Firstly, EuroInvestors regrets that the questions for public consultation raised in this report are clearly targeted to the insurance industry and insurance distributors, and not to customer organizations. This is maybe due to a certain lack of representatives of customer organizations in the EIOPA stakeholder groups and task forces that have written this report and made the preceding studies. We hope and very strongly recommend EIOPA to involve more representatives of customer and savers organizations in its expert groups and committees following the example of the other European bodies. Secondly, we consider that VA products should be classified as PRIPs as should be all other more “traditional” classical and with profit life insurance products. There should be no difference of treatment or disclosure between those products which are purchased for investment or retirement purposes. In fact VA products offer a different approach from that of these traditional products, but the same objective of providing benefits for retirement. It is therefore very important to ensure a good level of comparability between these products when advising to the client and they should not be subject to significantly different rules. Therefore, we consider that EIOPA’s recommandations for VA products concerning products features, costs transparency, level of products charges, selling practice and intermediary due diligence, apply also to the other traditionnal life and annuities products. Nevertheless, we want to stress that VA products are very complex in the sense that they incorporate (or are a mix of) two different categories of life insurance products: traditional with profit or unit-linked on one hand and annuities on the other hand. It is therefore very important that these products should be sold only on an independent advise basis and that the risks inherent to these products in terms of negative real performance, consumption of capital at the beginning of the payoff period, if any be very clearly stated. In order to insure a satisfactory level of fairness and accuracy we would welcome the use of independent experts, actuaries or financial experts, who would assess the merits of these products for a small investor according to some predefined objectives. The EuroInvestors' reply is to be found also on the following EIOPA's website: https://eiopa.europa.eu/consultations/consultation-papers/2011-closed-consultations/october-2011/report-on-good-practices-for-disclosure-and-selling-of-variable-annuities/index.html.

Position paper:
CP11-007_Comments_EFI1326295868.pdf

02/01/2012 EuroInvestors fully supports the position of the GCAE, emphasizing the necessity of correct, understandable and not misleading information about pensions. “Communication with the members should also explain in simple and clear terms the principal risks implicit in the financial arrangements, how they are managed and the potential consequences of failure. Better communication regarding the purchasing power of the benefits is essential and should, in our opinion, be an important factor in disclosure.” Moreover, transparency in communication with all stakeholders should be encouraged, leading to better understanding of the complexities and risks in pension schemes. EuroInvestors agrees with EIOPA that a new KIID-like document should be introduced and extended with information on contribution arrangements, practical information and cross/references to other document. Last but not least, the opinion of GCAE is shared  stating that “the HBS should be made public and communicated to stakeholders and especially plan members (present employees , retired and reversion beneficiaries) so that the employees get a better understanding of the exact nature of the promise being made to them and asses better the financial aspects of the plan sponsor covenant”.

Position paper:
EFI answer to EIOPA consultation on CfA on the review of Directive 2003 41 EC1326295813.pdf

03/01/2012 The European Federation of Investors (EuroInvestors) welcomes the opportunity to comment on the draft proposal for EIOPA’s Report on Good Practices for Disclosure and Selling of Variable Annuities (the “Report”). Firstly, EuroInvestors regrets that the questions for public consultation raised in this report are clearly targeted to the insurance industry and insurance distributors, and not to customer organizations. This is maybe due to a certain lack of representatives of customer organizations in the EIOPA stakeholder groups and task forces that have written this report and made the preceding studies. We hope and very strongly recommend EIOPA to involve more representatives of customer and savers organizations in its expert groups and committees following the example of the other European bodies. Secondly, we consider that VA products should be classified as PRIPs as should be all other more “traditional” classical and with profit life insurance products. There should be no difference of treatment or disclosure between those products which are purchased for investment or retirement purposes. In fact VA products offer a different approach from that of these traditional products, but the same objective of providing benefits for retirement. It is therefore very important to ensure a good level of comparability between these products when advising to the client and they should not be subject to significantly different rules. Therefore, we consider that EIOPA’s recommandations for VA products concerning products features, costs transparency, level of products charges, selling practice and intermediary due diligence, apply also to the other traditionnal life and annuities products. Nevertheless, we want to stress that VA products are very complex in the sense that they incorporate (or are a mix of) two different categories of life insurance products: traditional with profit or unit-linked on one hand and annuities on the other hand. It is therefore very important that these products should be sold only on an independent advise basis and that the risks inherent to these products in terms of negative real performance, consumption of capital at the beginning of the payoff period, if any be very clearly stated. In order to insure a satisfactory level of fairness and accuracy we would welcome the use of independent experts, actuaries or financial experts, who would assess the merits of these products for a small investor according to some predefined objectives. The EuroInvestors' reply is to be found also on the following EIOPA's website: https://eiopa.europa.eu/consultations/consultation-papers/2011-closed-consultations/october-2011/report-on-good-practices-for-disclosure-and-selling-of-variable-annuities/index.html.

Position paper:
CP11-007_Comments_EFI1326295868.pdf